https://www.taxtmi.com/caselaws?id=8592 Reassessment under sections 147 and 148 requires the assessing officer to have reasons to believe, based on material, that income escaped assessment because of the assessee's failure to make a full and true disclosure of primary facts. Disclosed balance-sheets, directors' reports and profit and loss accounts formed part of the return and showed the relevant sales and internal consumption figures, so the primary facts were already before the officer. A later reappraisal of the same facts on a different view of law amounted only to a change of opinion, which could not sustain reopening. The notices were therefore invalid and the reassessment proceedings failed. en-us Fri, 30 Apr 1971 00:00:00 +0530 Tue, 05 May 2009 16:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=8592 Reassessment under sections 147 and 148 requires the assessing officer to have reasons to believe, based on material, that income escaped assessment because of the assessee's failure to make a full and true disclosure of primary facts. Disclosed balance-sheets, directors' reports and profit and loss accounts formed part of the return and showed the relevant sales and internal consumption figures, so the primary facts were already before the officer. A later reappraisal of the same facts on a different view of law amounted only to a change of opinion, which could not sustain reopening. The notices were therefore invalid and the reassessment proceedings failed. Case-Laws Income Tax Fri, 30 Apr 1971 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=8592